Background

This policy statement is made pursuant to s.54 of the Modern Slavery Act 2015 and sets out the steps that Universal Networks has taken and is continuing to take to ensure that modern slavery or human trafficking is not taking place within our business or supply chain.

Modern slavery encompasses slavery, servitude, human trafficking and forced labour, all of which involve the deprivation of a person’s liberty by another in order to exploit them for personal or commercial gain. Modern slavery is a crime and violation of fundamental human rights

Our Business

Universal Networks’ supplies and maintains networking infrastructure systems. Offering a comprehensive range of quality products, our knowledgeable and technically trained staff provide personal advice and practical solutions to meet networking requirements, from a straight forward cable to a fully configured system. In partnership with many of the industry’s leading technology companies Universal Networks provides data network hardware, fibre optic and copper cables, armoured cable, network maintenance and consultancy.

Our High Risk Areas

Our risk relates to overseas procurement where we have little control over the recruitment and management of employees or workers in other countries where the laws may not be so robust.

Our Anti-slavery and Human Trafficking Policy Statement

Universal Networks has a zero tolerance approach to any form of modern slavery. We are committed to acting ethically and with integrity and transparency in all business dealings and to putting effective systems and controls in place to safeguard against any form of modern slavery taking place within the business or our supply chain.

Our Policies

We operate a number of internal policies to ensure that we are conducting business in an ethical and transparent manner. These include:

• Anti-slavery policy. This policy sets out our stance on modern slavery.
• Recruitment policy. We operate a robust recruitment policy, including conducting eligibility to work in the UK checks for all employees to safeguard against human trafficking or individuals being forced to work against their will.
• Whistleblowing policy. We operate a whistleblowing policy so that all employees know that they can raise concerns about how colleagues are being treated, or practices within our business or supply chain, without fear of reprisals.
• Code of business conduct. This code explains the manner in which we behave as an organisation and how we expect our employees and suppliers to act.

Our Suppliers

Universal Networks operates a supplier policy and maintains a preferred supplier list. We conduct due diligence on all suppliers before allowing them to become a preferred supplier. This due diligence includes an online search to ensure that particular organisation has never been convicted of offenses relating to modern slavery.

In addition to the above, as part of our contract with suppliers, we expect our suppliers to:

• Have taken steps to eradicate modern slavery within their business
• Hold their own suppliers to account over modern slavery
• (For UK based suppliers) Pay their employees at least the national minimum wage / national living wage (as appropriate)
• (For international suppliers) Pay their employees any prevailing minimum wage applicable within their country of operations
• We may terminate the contract at any time should any instances of modern slavery come to
  light

Training and Communication

As a small business we draw our employees attention to the Modern Slavery Act and ensure that our procurement team understand the signs of modern slavery and what to do if they suspect that it is taking place within our supply chain.

Our Performance Indicators

We will know the effectiveness of the steps that we are taking to ensure that slavery and/or human trafficking is not taking place within our business or supply chain if no reports are received from employees, the public, or law enforcement agencies to indicate that modern slavery practices have been identified.

Breaches of this Policy

Any employee who breaches this policy will face disciplinary action, which may result is dismissal for misconduct or gross misconduct.

Any individual or organisation working on our behalf breaching this policy will have their contract or agreement terminated.